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taxpayers had losses from 1976 to 1986, we held that they had a
bona fide profit objective during the years in issue, 1982 to
1984. Id. Respondent's case is much stronger here than in
Siegal v. Commissioner, supra. Petitioner's farm had no
profitable years from 1985 to 1993 and had a profit in only 1
year out of the 37 years that she operated it.
Petitioner contends that she made money from selling three
horses: (1) Good Mixture in 1972 or 1973 for $18,000; (2)
Rimrock in 1977 for $7,000; and (3) Thatcher in 1991 for
$35,000.3 Petitioner's claim that these sales show that she had
a profit objective is unconvincing. Those isolated sales, in
view of her losses, do not show that she operated the farm with a
profit objective.
Petitioner points out that she had unexpected losses during
the years in issue from the theft of livestock, a decline in the
sheep market, and unanticipated equipment repairs. Unforeseen
losses beyond the control of the taxpayer are considered in
deciding whether the taxpayer conducted the activity for profit.
Sec. 1.183-2(b)(6), Income Tax Regs. Petitioner has not shown,
however, that without these losses her farm would have been
profitable.
This factor favors respondent.
3 Petitioner also sold Fraulein Oneonta for $1,200 in 1988.
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